Commission Document Attachment

FCC-13-64A4

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RE: Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications, PS Docket No. 11-153; Framework for Next Generation 911 Deployment, PS Docket No. 10-255.
The digital age has multiplied the ways we communicate. With our mobile devices almost always in hand, we stay connected like never before. But reaching out today means more than talk. It means texting, too. We text to contact friends and family, to confirm plans, to vote in contests, and to donate to charities and campaigns. In light of this, last year the Commission took steps to make it possible to text in times of emergency—to text 911.
Today we build on this earlier effort. Specifically, we address consumer confusion regarding the availability of texting to 911. This is important. Because texting to 911 is not yet uniformly available, it is hard for consumers to know where this feature works and when it can be used. Yet when it comes to matters of public safety, our policies have no room for confusion. Simply put, it can be a matter of life and death.
To reduce this possibility, I believe the Commission needs to focus on three essential things.
First, consumers should have the confidence that comes from a firm date by which everyone can text to 911 nationwide. Last year the four nationwide wireless carriers agreed to provide this certainty by committing to offer the service by May 15 of next year. So far, so good.
Second, we need an extensive consumer outreach program, involving the Commission, public safety organizations, carriers, and the deaf and hard-of-hearing community all working together. Although we are only at the beginning stages of this effort, we are making progress.
Third and finally, consumers should receive an immediate notification—a bounce back message—any time their text to 911 does not go through.
It is this final point the Commission addresses today. It is absolutely critical. For too long, when a call for help went out as a text message, the only response was painful silence. But no one should be left wondering in an emergency if they have been heard.
Accordingly, in this decision we ensure that by September 30 of this year, consumers will have the confidence of knowing whether or not their text to 911 has gone through. Even better, this critical capability will not be limited to wireless carriers. IP-based texting applications that are increasingly substituting for traditional SMS text services will also begin providing bounce-back messages.
But as good as this is, the job is not done. I think more work is needed to clean up the bounce back messages so that are provided.
Here’s why. I have visited half of the active text to 911 trials that are ongoing across the country. I have seen text to 911 in action in Vermont, Maryland, and Virginia. What I learned is that while the numbers of texts received today is low, the potential is great. But I also learned about the bounce back messages in place today. They run the gamut—from helpful to confusing, from reliable to simply unavailable.

Federal Communications Commission

FCC 13-64

Some, consistent with today’s decision, provide two critical pieces of information—that text to 911 is not available and that the consumer should try to contact 911 using another means. For instance, from one carrier: “Call 911 for emergency. Text to 911 service not available.”
But others are a mix. From one carrier: “You have entered an invalid address.”
From another: “Message failed would you like to retry?”
From yet another, even worse: no response.
We can do better. So it is both my hope and expectation that before September 30, the carriers and providers of IP-based texting applications that are covered by this decision will develop a more consistent and more meaningful bounce-back message. They should. Because this is not just about reaching out, it is about communicating when the unthinkable occurs—and making sure that every call for help gets answered.

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